While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
There are no indigenous people around the project location that may be affected by the project, thus PS7: Indigenous Peoples is not applicable. Izsu is not expected to encounter issues covered by PS8 Cultural Heritage in this project as the project sites do not have any features of historic or cultural value. However, since the Yeni Foca area is a known ancient settlement area, as per the ESAP, Izsu will develop and provide a copy to IFC of a formal chance finds protocol as part of its management program for this project, providing appropriate protection in the event of unexpected discovery of items of cultural heritage.

This project has been classified as a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy as the environmental and social risks (E&S) and its potential impacts are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria. The project is expected to have positive environmental impacts as the waste water new treatment plant and sewerage system will replace the existing septic tanks will help to reduce risks of soil and water contamination and community health hazards.

The key E&S issues include: identification and management of construction and operational phase occupational health and safety risks, treated effluent discharge, external communication, community engagement, reporting to the affected communities, management of land acquisition, potential impacts on biodiversity and effect on cultural heritage.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System/Policy/Identification of Risks and Impacts/ Management Programs:



Although Izsu does not have a certified E&S management system, it has a documented management system consisting of identification of risk and impacts in line with Turkish Environmental and Occupational Health and Safety legislation, safe working practices, waste water treatment plant operational procedures, evaluation of legal compliance, emergency preparedness, monitoring and reviewing environmental performance, and communication with interested parties.



According to the decision by Ministry of Environment and Urban Planning, Environmental Impact Assessment and Monitoring General Directorate dated 11/24/2011, no Environmental Impact Assessment (EIA) is required for this project under Turkish regulations and the project has been approved by Ministry of Environment and Urban Planning, Environmental Management Directorate.



There will be a consultation process (including but not limited to surveys) in line with PS 1 requirements. Based on the results of this process Izsu will cooperate with IFC in addressing any significant issues that may arise.



As per ESAP, Izsu will develop and provide a copy to IFC of the occupational health and safety risk analysis for both construction and operational phases and related mitigation plans including an environmental & social management plan and operational procedures. Mitigation measures will include but not be limited to documented safe working instructions including personal protective equipment usage, confined space entry covering operations with the sewerage network and manholes.



Organizational Capacity and Competency:



The majority of the employees working at Izsu have an E&S related technical background. Izsu’s Project Department has the overall responsibility for the design of the project. Contractor selection and construction monitoring will be performed by Construction and Investment Department The treatment plant will be operated by Waste Water Treatment Department where sewerage network operations and maintenance will be within the responsibility of Infrastructure Department.



Izsu has dedicated environmental engineers and technicians in each of its waste water treatment plants. There is an OHS organization, including 3 OHS experts within the organization who report to Waste Water Treatment Plant Department Manager and technicians. For the construction phase, contractors are required to assign OHS experts by contractual agreements. Usev Contracting and Bulas Contracting has employed 3 OHS experts for conducting site inspections, EHSS performance reporting to Izsu, conducting impact assessments and risk analysis, supervising the staff on EHSS topics and conducting EHSS trainings.



Emergency Preparedness and Response:



Izsu has documented emergency and response plans including firefighting, first aid, evacuation, chemical spills, and search and rescue evacuat
ion and responses to accidental release of chemicals and spills. For Yeni Foca waste water treatment plant, a fire alarm system will be installed at the offices and fire extinguishers will be located as required by related Turkish legislation. Chemicals will be stored in well ventilated areas, away from direct exposure to sunlight on non-permeable storage areas.



Monitoring and Review:



Izsu has a waste water influent and effluent monitoring program in place with regulatory and IFC requirements. Izsu will adapt its program to cover Yeni Foca waste water treatment plant operations and there will be online monitoring devices to control the process and necessary tests will be conducted at various stages of the operations. Performance of other Izsu treatment plants are benchmarked periodically and best practices are shared between the plants.

Human Resources Policies and Procedures/Working Conditions and Terms of Employment/Workers’ Organizations:



Izsu currently employs almost 5,250 employees. Yeni Foca WWTP and sewerage network operations are expected to create additional jobs for approximately 14 new employees. As Izsu is a 100 % owned subsidiary of IMM, recruitment, terms of employment, working conditions are defined and provided according to Turkish “Public Employees Personal Regulations”.



There is no prohibition or discouragement of freedom of association and Izsu employees and its contractors are members of trade unions which are active in IMM, including Belediye Is, Tum Bel-Sen,Tum Yerel Sen, Turk Yerel Hiz-Sen, turkiye Bel-Bir-Sen and Ufuk Yerel Sen.



Non-discrimination and Equal Opportunity:



In line with the legislation in force, Izsu has policies against discrimination on the basis of personal beliefs or other characteristics that are unrelated to a person’s ability to perform his/her duties.



Retrenchment:



Izsu is not anticipating retrenchment as the areas of responsibility of IMM recently expanded. On the contrary, the project will create new jobs.



Grievance Mechanism:



There is a documented formal internal grievance system in place where employees can raise and register their concerns, including through anonymous reporting. Grievances raised using this mechanism are reportedly limited to around 5-6 per year and generally related with behaviors of other employees.



Protecting the Work Force:



In line with Turkey’s related legislation, the minimum age for employment is 18 in both IMM, and in Izsu. Turkish labor laws in place restrict child and forced labor in line with ILO standards.



Occupational Health and Safety:



Izsu has documented procedures and instructions for site safe working practices, personal protective equipment (PPE) usage, working with chemicals, manual handling, and operational procedures for waste water treatment plant operations. As noted under PS 1 above, Izsu will develop and provide a copy to IFC of the occupational health and safety risk analysis for both construction and operational phases and related mitigation plans including an environmental & social management plan and operational procedures.



Onboarding and orientation programs for new employees and periodical refreshment training includes EHSS topics such as job specific risks and measures, safe working practices, emergency procedures, waste management, chemical safety, and first aid.



Staff and new employees are subject to periodic health tests including respiratory function and audiometry checks.



Workers Engaged by Third Parties:



Izsu plants employs almost 50 contract employees for maintenance, security, catering services and employee transportation. During construction phase of Yeni Foca WWTP and sewerage network almost 100 contractors will be hired for mechanical, electrical and civil works. As a part of the existing standard wording of the contrac
t requirements, contractors are required to follow Turkey’s E&S and OHS legislative requirements, including conducting risk assessments, nomination of OHS experts and EHSS training to employees. Usev and Bulas Contracting hires rooms from some small hotels in Yeni Foca for the accommodation needs of their contractor employees.

Yeni Foca WWTP has a design capacity of 3.650.000 m3/year (10.000 m3/day) with 1.161 tpa sludge cake (20-25 % dry material) generation. Yeni Foca WWTP will be treating domestic sewage and there will be no industrial discharges the collection system serving the plant. Treatment process will include coarse and fine screening, sand and oil removal process, phosphorus removal, aeration tanks, final clarification and ultra violet (UV) disinfection. Treated waste water will be discharged to a dry river bed. The open part of the river will be rehabilitated by Izsu and will be connected to an underground pipeline which passes under a public road and is connected to the sea approximately 500 m from the WWTP. The planned WWTP’s removal efficiency is expected to be 93 % for biological oxygen demand, 85 % for chemical oxygen demand, 91 % for suspended solids and 80 % for nitrogen and phosphorus. Effluent quality of treated waste water will be in line with Turkish legislation requirements (adapted from EU regulations) and except for total nitrogen, with WBG’s General Environmental Health and Safety Guideline values. For total nitrogen, the design effluent criteria is 12 mg/l whereas Turkish legislation requirement is 15 mg/l and WBG’s general EHS Guideline value is 10 mg/lt. As the receiving body is a river bed which discharges to the sea, the differential of 2 mg/l of nitrogen is considered unlikely to have any significant adverse impact on people or biota. More importantly, Izsu’s existing WWTPs in Menemen, Old Foca, Reisdere, Cesme, Doganbey are operated with total nitrogen discharge level of below 10 mg/l despite the fact that their design specifications are 12 mg/l.



Sludge will be collected in a sludge thickener and will be dried to 20-25 % dry material. Dried sludge will be transported by truck to Izsu’s sludge digester and drying facility in Cigli, almost 50 km away.



Resource Efficiency:



Specific electricity consumption is expected to be around 2.644.000 kWh/year. Electricity will be provided from national grid.



GHG Emissions:



The main source of GHG emissions is the sludge cake generation and electricity consumption. Carbon dioxide (CO2) equivalent emission is estimated to be approximately 1.350 tpa.



Water:



Water consumption will be negligible as the consumption will be limited with treatment plant chemical preparation and domestic usage for the employees.



Air Emissions and Ambient Air Quality:



The point source air emissions will be limited to a few emergency generators which are small and below the threshold at which IFC and/or Turkish authorities require emission monitoring.



Solid Waste Management:



Construction wastes will include excavation wastes mainly from sewerage network construction and will be landfilled in IMM’s construction waste sites. Operational wastes will include mainly the containers and packages of laboratory chemicals, cleaning substances and waste water treatment plant chemicals (ferric chloride an
d poly electrolyte). Recyclable wastes including packaging and office wastes will be recycled by third party licensed waste companies and all other wastes will be sent to IMM’s landfill in line with other Izsu WWTP waste management practices.



Hazardous Materials:



Hazardous materials will include laboratory chemicals and solvents for cleaning purposes and laboratory tests. It is planned to use ferric chloride and polyelectrolyte for the sedimentation, sludge drying and phosphorus removal process. Existing chemical storage areas in other Izsu WWTP’s have specific control measures including spill kits, secondary containment, fire safety, and emergency showers. Yeni Foca WWTP will have similar measures and a separate closed, well ventilated chemical storage area. As in other Izsu WWTP, material safety data sheets for the hazardous chemicals will be provided and shared with the employees at the point of usage.

Community Health and Safety:



In order to manage potential odor, the project includes installation of activated carbon filters to sludge thickener and sludge drying units in the WWTP and at some transfer stations on the sewerage network.



The construction of the sewerage network will be within existing Yeni Foca residential areas. As per the attached ESAP, Izsu will develop and provide a copy to IFC of the documented construction safety measures that relate to protecting the community, including clear demarcation of WWTP construction site / sewerage network excavation areas; restricted access to construction areas; proper illumination of the areas; and rules for traffic safety to ensure safe movement of construction vehicles.



For the operational phase, daily sludge cake transport by truck from Yeni Foca WWTP to Cigli will also be covered by transportation safety measures, as reflected in the ESAP.



The downstream section of river where the treated waste water will be discharged is not used for irrigation. The closest beach is around 150-200 meter away from the point of discharge. Discharge will occur a few meters under the sea surface. As a part of another project, in addition to advanced biological waste water treatment Izsu has completed technical studies including oceanographic and dilution modelling to extend the discharge pipe to allow discharge through a pipe, which will extend 600 m on land to the beach and a further 500 m from the beach into the sea (in consultation with Ministry of Environment). This will be another project, for which the tender is expected to be completed by the end of 2015, with project completion estimated at around 12 months.



Security Personnel:



Izsu will employ unarmed private security personnel who will be trained in the use of force for defensive purposes.

The whole Foca Peninsula, has been identified as an Important Bird Area (IBA) and Key Biodiversity Area (KBA) according to The International Union for Conservation of Nature (IUCN) on the basis of the presence of significant populations of globally threatened species on its red list including the Mediterranean Monk Seal (critically endangered), Spur-thighed tortoise (vulnerable) and Bonelli’s Eagle (least concern). Foca (Eski Foca), which is almost 20 km away from Yeni Foca, is a national protection area for the seals and Yeni Foca is within the “seal’s feeding area boundaries” according to Turkish Ministry of Environment publications. In line with existing Turkish legislation, Izsu has obtained Izmir City’s Cultural and Natural Resources Protection Committees approval dated 05/23/2012, number 886 for the project.



Despite the sensitivity of the peninsula as a whole, the WWTP and sewage network are to be located in a modified habitat surrounded by agricultural fields and / or by residential houses. As such, and as the Aliaga Heavy Industrial Zone (which includes 25 ship demolition facilities, 2 petrochemical plants, around 11 iron steel plants, 2 combined cycle gas fired power plants and 15 other plants from various sectors including chemicals, fertilizers, textile, paper, etc.) is located 7-8 km east of the waste water treatment plant location, the incremental impact of the project on the species of interest is considered to be negligible.

Yeni Foca WWTP will be constructed within a few hundred meters of residential houses and the sewerage network will be linking residences to the WWTP. Although no EIA was conducted for the project, there are several banners and signs on display in Yeni Foca that present the route of the sewerage network and the proposed WWTP location. As discussed in PS1, above, there will be a consultation process to consult with these parties prior to construction, focusing on persons living close to the treatment plant and discharge point as well as businesses possibly impacted by temporary sewerage pipe laying activities. The municipality will work with IFC to mitigate any significant impacts identified during this consultation process.

Izsu has a formal external grievance mechanism where affected communities can raise and register their concerns, and which provides information about its planned and ongoing projects. The grievance mechanism is to be found on its website (http://www.izsu.gov.tr) As part of IFC’s involvement, the sponsor will ensure that the Yeni Foca WWTP and Sewerage network construction project is included on the page related with future and/or ongoing projects and that there is a functioning community grievance redress process available to affected persons.

IZSU annually discloses its WWTPs’ performance on its website, which includes key performance indicators related with waste water treatment plant projects, collection system improvement, and its other projects including Izmir Bay rehabilitation and drinking water from sea water projects. In general, IMM and Izsu maintain good relations with local communities and customers.

Izsu has been involved in a range of community engagement and social responsibility activities including organization of conferences on water consumption.

IMM has a community engagement program, “Izmir City Council” where NGOs can attend and discuss their concerns. The citizens can also attend as audience to the Municipal Council meetings. Izsu will continue to perform and extend community engagement activities with IMM in a structured manner as defined by related Turkish Legislations, “Municipality Law - # 5393” and “City Council Regulation - # 26313”.

For more information please contact:

Name : M. Guven Agar
Address: Cumhuriyet Bulvari No. 16 Konak / Izmir
Tel: +90 232 293 2293
e-mail:
http://www.izsu.gov.tr

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Izsu will develop and provide a copy to IFC of the occupational health and safety risk analysis for both construction and operational phases and related mitigation plans including an environmental & social management plan and operational procedures. Mitigation measures will include but not limited to; 1) documented safe working instructions including personal protective equipment usage, confined space entry covering operations with the sewerage network and manhole; 2) traffic and transportation safety measures that may arise from transportation of sludge cake from Yeni Foca WWTP to Cigli Sludge Digester and Drying Facility by trucks; 3) a documented formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.	07/31/2015
Izsu will develop and provide a copy to IFC of the documented construction safety measures that relates to protect the community, including clear demarcation of WWTP construction site / sewerage network excavation areas; restricted access to construction areas; proper illumination of the areas; rules for traffic safety to ensure safe movement of construction vehicles.	07/31/2015
IMM and Izsu will ensure that the outcome of the valuation / compensation process will be in line with PS5 requirements. Where gaps are identified IMM and Izsu will agree with IFC on a time based action plan to address these.	07/31/2015